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Episode 313 — The Coming Sanctions Criminal Corporate Enforcement Storm

There are some things you learn best in calm, and some in storm.  Will Cather DOJ has promised an aggressive criminal corporate enforcement program against sanctions violators. The storm is coming and will arrive soon with a bang. There is no question that DOJ’s enforcement initiative is coming — it is just a question as to when. In this Episode, Michael Volkov reviews the elements...

Former Stericyle Official Charged in Foreign Bribery Scheme

According to the terms of a superseding information made public by the U.S. Attorney’s Office for the Southern District of New York on or about February 13, 2024, Mauricio Gomez Baez (“Baez”)—a former Stericycle executive for Latin America—was officially charged with a single count of  conspiracy for his role in a multi-year scheme to expand Stericycle’s business opportunities in the Latin American region (particularly, Mexico,...

Ex-Vitol Oil & Gas Trader Convicted of Bribing Foreign Officials

Following an 8 week trial, a federal jury in Brooklyn has convicted Javier Aguilar on charges relating to the former Vitol trader’s violations of the Foreign Corrupt Practices Act. He faces up to 30 years in prison. Aguilar bribed officials in Mexico and Ecuador to obtain contracts from their state-owned oil companies. He was also convicted of using a complex money laundering scheme to avoid...

Justice Department Focuses on Artificial Intelligence Assisted Crime

In the face of rapid technology changes, the Department of Justice usually has to play catch up.  When cryptocurrency and blockchain entered the United States economy, the Justice Department played catch up.  Fraudsters and other criminals innovate and embrace new technologies to prey on victims.  The Justice Department usually catches up but there is often a lag as “innovative” criminals gain certain market advantages.  DOJ...

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The UK Modern Slavery Act: Easy Wins and Practical Compliance (Part II of II)

In Part I, we discussed the basics behind the UK Modern Slavery Act of 2015.  To briefly reiterate, that Act requires any company doing business in the UK with an annual turnover of £36 million or more to publicize their efforts in combatting modern slavery in their respective supply chains through an annual statement.  The Act itself established minimum requirements for these statements, but there...

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Compliance With the UK Modern Slavery Act: What It Means for Companies (Part I of II)

If you follow our blog, you’ll notice lately we’ve been writing frequently on topics related to human trafficking and modern slavery.  This is no accident, as new laws and regulations related to this growing area of compliance continue to spring into existence.  Lately, I’ve fielded some inquiries related to the UK Modern Slavery Act of 2015.  While the Act is not necessarily new, there has...

Episode 312 — Eddie Green, CEO of SnippetSentry, on Communications Preservation Risks

Companies have a vested interest in preserving internal communications for a variety of reasons — to hold actors accountable and to protect the organization from potential private and government claims or investigations that may have serious direct or collateral consequences. Companies that want to use ephemeral messaging systems can do so, but they have to understand the risks involved and tailor appropriate controls and procedures...

A Deeper Dive into Supply Chain Transparency & Accountability

The sheer proliferation of supply chain transparency and accountability regulations at international scale itself warrants a closer look at the level of scrutiny required of organizations with complex, multi-faceted, global, and increasingly interconnected, supply chains. Legislation as varied as the German Supply Chain Act, the Uyghur Forced Labor Prevention Act, and proposed legislation for a more comprehensive due diligence framework at the European Union (“EU”)...

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President Biden Issues Executive Order Concerning Bulk Data, With Parallels to Current Sanctions Regulations

On February 28, 2024, President Biden issued a new Executive Order in order to better secure the private data of U.S. citizens from being exploited by foreign adversaries of the United States.  By issuing his Executive Order on Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern, President Biden has directed the U.S. Department of Justice (“DOJ”),...

Diligent and Volkov Law Partner to Host Virtual Roundtable Highlighting Current Compliance Priorities

On Tuesday, February 20, 2024, Michael Volkov and Alexander Cotoia participated in a virtual roundtable hosted by Diligent Institute as part of a monthly series dedicated to providing updates to those who have availed themselves of Diligent’s well-reputed certification programs for senior corporate officers and directors. As part of the roundtable, Volkov Law highlighted current topical issues, including enforcement trends and compliance-oriented mitigation strategies focusing...